CP 201, CP 209 (EIN consolidation): Two EINs for one entity: mismatch, or merged

What CP 201, CP 209 (EIN consolidation) is

CP 201 tells a business that a request to consolidate two EINs failed because the name controls on the two accounts do not match; CP 209 confirms a successful consolidation, with the surviving EIN (IRM 3.13.2.14.1, 3.13.2.20). A vendor with two EINs and two name controls is a standing source of 1099 mismatches; the manual notes many consolidations exist because a taxpayer was on file with two different name controls.

The deadline

Per the notice.

What to do

Ask which EIN survives and re-solicit a W-9 with that EIN and the legal name.

How a business ends up with two EINs

An EIN is meant to be permanent, but businesses acquire a second one more often than the rules suggest: a bank or payroll provider applied for one without checking, an owner applied again after misplacing the first, a conversion from sole proprietorship to LLC or from LLC to corporation was handled by applying fresh when the existing number should have carried over (or the reverse), or a predecessor's number was kept in use after a merger. Each EIN has its own name control and its own filing requirements, and the IRS treats them as two taxpayers. The consequences land on information returns: the vendor's W-9 carries one EIN and the name that matches the other, TIN matching fails, a CP2100 lists the vendor, and the vendor insists the number is right. The IRS can consolidate two EINs into one when both belong to the same entity, but only if the names on the two accounts produce the same name control; when they do not, the request fails and CP 201 says so. CP 209 confirms a successful consolidation and tells the business which EIN survived.

What the payer needs from the vendor

A vendor that mentions a CP 201 or CP 209 is telling you that its EIN situation was unstable until recently, and any W-9 you took before the consolidation may carry the dead number. Ask for a new W-9 with the surviving EIN and the legal name exactly as the IRS now holds it, and ask the vendor to attach a Letter 147C dated after the CP 209; the 147C is the only document that shows the pairing the IRS will match. If the vendor's consolidation failed (CP 201), the vendor has to fix the name on one of the accounts first, which the Letter 252C page describes, and in the meantime you should match against whichever EIN and name the vendor can document with a 147C. Run the new pairing through TIN matching before the next payment. The name control page explains why two spellings of the same company can produce two name controls, and the vendor name change guide covers what to do with 1099s already filed under the retired number.

Questions about CP 201, CP 209 (EIN consolidation)

Have a different notice? The IRS notice decoder lists all 77 in the order they tend to arrive.